New Legislative Framework (NLF) - Interpretative Fiches
Further to its 11 October 2010 position paper, Orgalime is pleased to provide a set of concrete recommendations for the smooth application of product legislation that applies the rules of the New Legislative Framework (NLF) for the placing of products on the Community market. We hope that the Commission and member states will find inspiration into them with a view to revise the valuable EC Blue Guide to the 'implementation of Directives based on New Approach and Global Approach'.
These interpretative fiches are addressing the following issues:
Obligations of economic operators:
Fiche n°03: Translation requirements, in particular of the Declaration of Conformity (DoC)
Fiche n°04: Traceability requirements: Conditions for affixing the name and address of the manufacturer and/or the importer on the product itself
Fiche n°17: How far the obligation of the importer should go?
Fiche n°05: Scope: clarification of the definition of accreditation for the purpose of notification
Conformity assessment (CA):
Fiche n°08: Proportionality in the application of CA procedures, esp. for small and medium sized companies
Fiche n°09: Requirements for accredited in-house CA bodies with a view to ensure fair competition between in-house accredited bodies and other bodies vis-à-vis notification
Fiche n°10: Clarification of the definitions with regard to the application of CA modules
Fiche n°11: Content of the Technical Documentation to be provided on request to authorities
Fiche n°15: There should be no enforcement incentive to third-party certification.